-- Download WCS position paper in the following link --
The current coronavirus (COVID-19) global pandemic is killing thousands of people globally and causing major impacts to livelihoods, society, and economies across the world. COVID-19 is understood to have originated in wildlife, most probably in a market selling live wildlife in China (Cyranoski, 2020; Lu et al., 2020; Zhang et al., 2020; Zhou et al., 2020).
The conditions that lead to the emergence and transmission of these zoonotic pathogens to humans are also prevalent in Viet Nam (Cantlay et al., 2017; Li & Li, 2020; Webster, 2004). It is time for the current approach to regulating trade and promoting the use of live wildlife to change, for the wellbeing and survival of all on this planet.
► The wildlife supply chain (legal and illegal) provides ideal conditions for the creation, emergence and transmission of zoonotic pathogens
Wildlife is commonly traded and used in Viet Nam for meat, pets, skins, traditional medicine, or display in private zoos/collections. Animals from a wide range of species are sourced in Viet Nam, neighboring countries, and from across the globe and include those trapped from the wild or sold from captive breeding facilities. From source to market, the wildlife supply chain (both legal and illegal) involves conditions that present a high risk for the emergence and transmission of zoonotic pathogens which could potentially cause future pandemics such as COVID-19, as evidenced by SARS, H5N1, and MERS (Can et al., 2019; Murray et al., 2016; Li & Li, 2020; Webster, 2004):
● Different species of wildlife are stored (dead and alive), and housed, dead and alive at high densities and in close proximity to each other and domestic animals in restaurants, pet shops, wholesale markets, wholesale trader houses/warehouses, and commercial breeding farms. They also come together for shorter periods of time in high volumes as they pass international boundaries. There is exchange and introduction of animals to the same or adjacent enclosures without disease screening or quarantine procedures.
● During time in transport and storage wildlife is kept in confined conditions where vermin, people, and fomites pass between cages/enclosures. Husbandry conditions are often poor or inappropriate to that species e.g. fecal matter not cleaned and poor diets which generally leaves animals in a stressed, weak, and immuno-compromised state. Wildlife are often kept at high densities in enclosures during trade which facilitates pathogen transmission and virus spill-over events from different species
● The slaughter and preparation of animals for consumption often takes place in close proximity to live animal cages and in an un-hygienic manner further spreading viruses and sharing potential pathogens
● Evidence from recent studies in Vietnam suggest that as wildlife moves along the wildlife supply chain, from capture site to the restaurant plate, the prevalence and diversity of pathogens increases highlighting the increasing risk of pathogen transmission and novel viral emergence along the wildlife trade chain (Nguyen et al., in prep).
► Corona viruses (and other viral families) occur naturally in wildlife and have been found at multiple points along legal and illegal wildlife supply chains in Viet Nam
Scientists have detected a wide range of viruses (including corona viruses) in free-ranging wildlife but also in animals along the legal and illegal wildlife trade supply chain in Viet Nam, and multiple other countries where humans harvest, trade, and consume wildlife (Bueno et al., 2016; Cantlay et al., 2017; Nguyen et al., in prep). This includes wildlife farms, shipments, and in markets. Research has found the highest rates of detection in species of mammals and birds (Olival et al., 2017; Carroll et al., 2018).
These human-wildlife super-interfaces we have established along the wildlife trade supply chain harbor the perfect conditions for the creation of novel viruses. Through re-assortment, realignment and exchange of viral components among a diversity of wildlife species, new viruses are created and sometimes, one of these novel viruses can enter and multiply in a human cell causing infection (Parrish et al., 2008; Tao et al., 2017). Every once-in-a-while this novel virus will then transmit between humans, laying the foundation for a potential pandemic. As humans increase contact with wildlife populations, particularly under the above conditions, the risk of the emergence of a new viral pathogen and subsequent human disease is massively accelerated (Murray et al., 2016; Plowright et al., 2017).
Increasing sampling along the wildlife trade chain will add to the already solid evidence base that establishes the prevalence of viruses in different species, but due to the rareness of the event it is unlikely that even with increased surveillance we will be able to create systems that can detect or identify every pathogen ahead of a spillover event where it is transmitted to humans (Bueno et al., 2016; Murray et al., 2016). It is important to heed the warnings in existing information. Our strategies need to be focused on reducing these interfaces and points along the supply chain that promote the creation, emergence and transmission of pathogens. This means significantly reducing the volume and diversity of species traded, and reducing the number of people involved in the trade of wildlife.
► Recommended policy reform
The Prime Minister of Viet Nam appointed Ministry of Agriculture (MARD) to lead and coordinate with relevant Ministries to draft a Directive to prohibit the trade and consumption of wildlife (Official Letter No. 1744/VPCP-KGVX dated 6 March 2020 of the Government Office).
Previous Prime Minister Directives have focused on specific measures to control ongoing epidemics including SARS, H5N1 or COVID-19 (e.g. No. 11/2003/CT-TTg, No. 29/2006/CT-TTg, No. 05/2020/CT-TTg) whilst others have aimed to strengthen regulation and enforcement of existing laws to reduce illegal wildlife trade by the competent agencies (e.g. No. 28/2016/CT-TTg, No. 3/2014/CT-TTg), and others prohibit trade in certain species for certain purposes (e.g. No. 11/2013/QĐ-TTg).
1) Prohibit highest-risk parts of the wildlife supply chain involving highest risk taxa
There is no such thing as risk-free trade and consumption of wildlife whether they are wild-caught or farmed. The conditions for viruses to emerge and be transmitted to humans occur in legal, regulated trade as much as in illegal markets (Cantlay et al., 2017; Li & Li, 2020; Webster, 2004).
To ultimately minimize the risks to public health of viral disease emergence from wildlife, we recommend the Prime Minister’s Directive to include specific precautionary measures that restrict the killing, commercial breeding, transport, buying, selling, storage, processing and consuming of wildlife to reduce the risk of a novel virus emerging along the wildlife trade value chain to safeguard both livestock-based production systems and human health, this would be in line with Article 16 and 18 of the 2015 Veterinary Law and Article 8 of the 2007 Law on Prevention and Control of Infectious Diseases.
Regarding the scope of the increased restrictions, the Prime Minister in his Letter 1744/VPCP-KGVX indicated prohibition of all trade and consumption of wildlife. There have been varied responses to that. WCS believes there are five main options to the Government and we provide the following analysis of those.
Scope of prohibition
All wild animals (wild caught or captive bred)
Eliminates the most risk of pathogen emergence or transmission. Requires a clear definition of “wild animals” as currently unavailable in Vietnamese law. Would impact seafood, freshwater fish/crab/snail and frog sector.
All wild amphibians, birds, mammals, and reptiles (wild-caught or captive-bred)
Easier to define for law enforcement, regulatory and management agencies. Reduced impacts on seafood/freshwater food sector. However, it requires a clear definition of ‘wild’ to mitigate impacts on frog farms.
All wild birds and mammals (wild-caught or captive-bred)
Wild birds and mammals are the highest risk taxon as hosts for zoonotic pathogens so by prohibiting these a significant level of risk would be reduced. Easier to define for law enforcement/regulatory agencies. Reduced impacts on seafood/freshwater food sector.
Wild birds and mammals (wild-caught or captive bred) where the end use is for a live animal or food
By restricting actions according to the end use, as China has done, adds a risk of confusing law enforcement and management agencies as they have the burden to show the intended end-use. This creates a loophole and challenge for enforcement.
Wild animals listed as protected in Decree 64/2019, Decree 06/2019 or the CITES Appendices in Announcement 296/TB-CTVN-HTQT
Whilst this provides a list of species to prohibit trade/consumption, as shown by results of surveillance over last decade by MARD, Ministry of Health (MOH), WCS and others, many species that carry pathogens that could transmit to humans are species outside of any legal protection e.g. bamboo rats, civets, porcupine, macaque. So this option would be insufficient to prevent future zoonotic pathogen emergence.
Based upon the above analysis WCS recommends that the Government prohibits the hunting, killing, captive breeding, transport, trading, storing, processing, and consumption of wild birds and mammals (wild-caught or captive-bred).
It should be noted that the term ‘wild’ can be defined as any species not on the list of animal species permitted to raise as livestock (Decree 13/2020/ND-CP that provide detailed instruction for the 2018 Law on Animal Husbandry).
Accordingly, we recommend MARD to coordinate with Ministry of Natural Resource and Environment (MONRE) and the relevant ministries and agencies to review documents guiding the implementation of the Veterinary Law, the Livestock Husbandry Law, the Law on Biodiversity and Forestry to provide revised directions to ensure consistency with the proposal of prohibiting hunting, killing, rearing, capturing, transporting, trading, storing, processing and consuming animals of wild mammals and birds (wild-caught or farmed) as well as the corresponding penalties.
We recommend that the MOH coordinate with relevant ministries and agencies to review the 2007 Law on Prevention and Control of Infectious Diseases, specifically, Article 8 and associated Decrees and Decisions in light of the COVID19 outbreak, and provide recommendations for required revisions.
2) Enhanced enforcement and judicial response to combat illegal wildlife trade
Law enforcement and judicial agencies should be directed to investigate and bring to justice with high penalties individuals and companies violating the above new policy and existing policies on wildlife protection.
The Anti-Money Laundering Department of the State Bank of Viet Nam should coordinate closely with the Environmental Police and Economic police of the Ministry of Public Security (MPS) to detect and handle suspicious transactions and risks linking to money-laundering crimes; simultaneously investigation agencies should strengthen the use of financial investigation tools and precautionary measures to target the profits of wildlife trafficking.
The MPS should be directed to increase coordination and cooperation with counterpart agencies in China and ASEAN member states to develop intelligence and identify priority targets for enforcement and report back on related arrests, prosecutions and convictions on an annual basis at minimum.
The MARD should coordinate with Ministry of Justice (MOJ), Ministry of Finance (MOF) and MPS to make annual report on handling of administrative wildlife violation cases.
The MPS should strengthen their coordination with Supreme People’s Procuracy (SPP) and Supreme People’s Court (SPC) to make annual reports on investigation, prosecution and adjudication of criminal wildlife trafficking cases.
Furthermore, the Government should develop a new multi-agency coordination mechanism to supervise the enforcement of this policy and existing laws on wildlife protection, as this is outside of the scope of the existing committee (VN-WEN).
3) Tighten regulation and oversight of commercial wild animal farms that produce skins and medicine products
The risks of viral emergence and transmission in wild animal farms that produce skins (e.g. crocodiles and pythons) and medicinal products (e.g. deer antlers) is not well understood.
We recommend the Prime Minister forms a multi-agency committee including Department of Animal Health (DAH), and Department of Livestock Production (DLP), CITES MA, Forest Protection Department (FPD) of MARD, and General Department of Preventive Medicine (GDPM) and National Institute of Hygiene and Epidemiology (NIHE) of MOH, and related agencies in managing quarantine and market regulation/food safety, to review wild animal farming operations and practices where the end use is skins or traditional medicine to make further recommendations that will minimize risk of pathogen transmission to humans.
4) Development of guidelines for the standard of safety during the handling of confiscated wildlife, to reduce the risk of disease transmission for law enforcers and rescue facilities
We recommend MOH and MARD to provide detailed guidelines to related ministries and agencies to review and provide recommendations on the promulgation of guidelines to ensure safety standards are met during handling confiscated specimens of wildlife (from the time of confiscating the animals to the final steps of handling the violation) to ensure risks of disease transmission to relevant agency and rescue center staff are minimized.
The guidelines should be developed pursuant to the Circular 29/2019/TT-BNNPTNT on handling of forest animals as evidence; and forest animals voluntarily submitted to the state by organizations and individuals.
5) Behavior change communication campaigns to change behavior of wildlife consumption
To minimize the risks of zoonotic pathogen emergence and transmission, the practice of consuming wildlife as meat or keeping of wildlife as pets needs to end. Government agencies should shortly promulgate detailed guidance or public campaigns on potential risks of consuming wildlife and their products.
The General Department of Preventive Medicine (MOH) should enhance their collaboration with relevant technical bodies from the Ministry of Information and Communication (MoIC), and concerned ministries, in consultation with the Central Committee for Propaganda and Education (CCPE) to develop a sustained campaign that utilizes behavioral science approaches to change the behavior of consuming wildlife.